At once we want to calm down, the Law does not change implementation of usual operations of citizens, and also clients of bank who are already identified :)
The law provides, in particular, for a new procedure for making payments and transferring funds by the Bank's clients.
From now on, cash transfers within Ukraine (Article 14 of the Law) in the amount of UAH 5,000 will require identification of the payer.
EXCLUSION
Please note that the provisions of Article 14 of the law do not apply to transactions:
- payment of housing and communal services, payment of taxes, fines, other mandatory fees and charges (regardless of the amount);
- loan repayment in the amount of up to UAH 30,000;
- transfers for payment of goods and services made by the payer using a payment card (or other electronic means of payment), if its number accompanies the transfer (regardless of the amount);
- all cash transfers within Ukraine in the amount of up to 5 thousand UAH;
- withdrawal of funds from own account.
The restrictions provided for in Article 14 of the Law do not apply to non-cash payments from bank accounts and payment cards, such transactions will be carried out as before, without additional identification.
We remind you that you can perform most banking operations remotely in the Internet banking system, and to make a cash transfer in the amount of 5,000 to 400,000, if the transaction does not arouse suspicion, a passport of a citizen of Ukraine is sufficient.
Additionally, the main changes to the Law are:
- the possibility of remote identification of clients for account opening is provided;
- Risk-Based Approach. Thus, a risk-oriented approach will change the approach to financial transaction control, which will help reduce bureaucratic procedures in identifying and verifying the client;
- increase in the amount of financial transactions subject to mandatory financial monitoring (from UAH 150 thousand to UAH 400 thousand) with a simultaneous decrease in the number of features of such financial transactions (from 17 to 4);
- the possibility of using the results of due diligence carried out by another subject of primary financial monitoring (remote identification);
- the procedure for disclosing the ultimate beneficial owners and the ownership structure of a legal entity have been improved. In addition, the Bank is obliged to inform the AMS in case of discrepancies in the information on the ultimate beneficial owner between the data from the USR register and the data obtained by the Bank during the due diligence;
- new approaches to work with public figures New law public figure a person who performs or has performed certain public functions regardless of any term. Therefore, the status of "public figure" is for life and is not limited to 3 years, as provided by current law. In addition, the list of persons who will be considered members of the public figure's family is decreasing.
Here is a copy of the answers to common questions:
❓I want to transfer UAH 10,000 from card to card to a relative. Are there any restrictions?
No. No changes for card-to-card transfers. Freely transfer both UAH 10,000 and UAH 25,000 (within the amounts allowed by the bank). The bank already has all the information about the cardholder. This is an identified client.
❓What if I have 10 thousand UAH in cash? How best to retell, and do you need additional verification?
This operation can be performed at a bank branch. This will require a passport.
Another way - transfer through self-service terminals, ATMs with the function of receiving cash. If such a device has a card reader, then the operation can be done for 10 thousand UAH and 20 thousand UAH.
If there is no such reader, and verification cannot be carried out, then everything is within the limit of 5 thousand UAH. Those financial companies that have not equipped the terminals with readers will have time to do so by the end of the year.
❓What about replenishing the credit card through the terminal?
Similarly. Up to 5 thousand UAH without identification. From 5 thousand - in the office or through PTKS, which can technologically provide verification of the payer.
❓I rent an apartment for 10 thousand UAH per month. I used to transfer this money to the owner of the apartment on the card. Do I need to split the payment now?
You do not need to split payments into installments. The law does not change anything for card-to-card transfers.
If you top up your card through a terminal, it all depends on whether such a terminal has a limit. If it is set at UAH 5,000, you will not be able to transfer more.
❓Okay. Then I will transfer UAH 5,000 to the card twice. Will it not be blocked?
No. This is a low-risk operation. Single transfers for 10 or 20 thousand UAH are not of interest to those who check them. And there is no need to confirm the origin of funds here.
Law on financial monitoring of other. Banks should focus on the highest risk areas - transactions over 400 thousand hryvnias, as well as unusual customer transactions. For example, a client trades in vegetables for 10 years and then transfers money to pay for scrap metal for hundreds of thousands of hryvnias. This is a strange, uncharacteristic operation. It is worth paying attention to this exotic case.
❓I buy a TV in an online store for 40 thousand UAH. What are the pitfalls here?
If you pay by card - nothing new. If the delivery of the TV will be through the postal operator, and payment by cash on delivery - then remember the rules of working with cash. The postman will ask you for personal documents.
❓How to deal with a transfer from abroad to a foreign currency account? Are there limits?
You are already an identified customer if you have a foreign currency bank account. There are no limits or restrictions set by the finmon law.
❓ I want to transfer 10 thousand hryvnias through the international transfer system. Do I need identification?
Yes, when performing this operation it is necessary to identify and verify the payer. That is, the client must have a passport with him and explain what kind of payment it is, for example, indicate in the details that it is assistance to relatives.
❓I go to the bank branch to make a transfer for UAH 100,000 or open a deposit for UAH 150,000. I took my passport. Do you need a certificate of income?
No, not required. Customers should not provide information on the sources of funds for simple transactions for "sub-threshold" amounts.
It is necessary to confirm the origin of funds only during large operations - more than 400 thousand hryvnias. The approach to the study of sources of origin has not changed.
❓And if the transfer is for 500 thousand UAH? And there are no sources of origin. Will the account be blocked and the funds on it "frozen"?
The Bank does not unreasonably block customer accounts if it has all the necessary information about them. When you opened an account, you filled out a questionnaire, provided information about yourself and income. The bank knows the history of the client's operations and knows which operations are familiar to him.
Agree, it is strange if a student who receives a monthly stipend of one thousand hryvnias, and then buys an apartment for a million hryvnias ?! At the same time, this will be a perfectly normal operation for a client with an average or above average income.
❓How to use an e-wallet? I heard that identification is needed now. And to replenish the mobile account is also needed?
Yes, identification and verification of e-wallet owners is required. But not the wallets used to pay for mobile services. An exception is made for them in the law.
You need to check the owners of wallets that buy goods through them or pay for services. There is also time for this until the end of the year. Required documents: passport and identification code. Transactions through e-wallets will be limited, and if the customer adheres to these limits, he will be able to pass a simplified identification.
If you have any questions, you can write to us at: alliancebank@alliancebank.org.ua
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